UK Sanctions Against Russia: Overview of Recent Developments

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The UK has announced 100 new sanctions targeting the Russian military, energy and financial sectors

On 20 May 2025, the UK announced a wide-ranging sanctions package against the Russian Federation. The sanctions were published in coordination with the European Union, which has announced parallel measures in its 17^th sanctions package against Russia.

The sanctions primarily target Russia’s military, energy, financial sectors and those involved in Russia information operations.

These latest sanctions announced have imposed asset freezes and restrictions on trust services on 20 individuals and 62 entities, including:

• the Social Design Agency (SDA), accused by the UK of being a disinformation body and previously sanctioned in 2024. The UK is now targeting all levels of the organization, including 14 more members of the SDA;
• the supply chains of Russian weapons systems, including Iskander missiles;
• five entities and individuals involved in the Russian energy and digital technology sectors; and
• fifty entities involved in Russia’s financial sector including the St Petersburg Currency Exchange (JSC SPCEX), Non-bank Credit Organisation Joint-Stock Company Petersburg Settlement Center (JSC PSC) and the State Corporation Deposit Insurance Agency (DIA).

The UK Government has issued General Licence INT/2025/6275812, which authorises the wind down of transactions involving either JSC SPCEX or JSC PSC, subject to certain terms and conditions. The General Licence expires on June 19, 2025. Similarly, the UK government has issued General Licence INT/2025/6279615, which authorises the processing of payments due to be paid to the DIA, subject to certain terms and conditions. The General Licence is of indefinite duration.

In shipping, the UK has sanctioned 18 more ships in the “shadow fleet” carrying Russian oil, along with the fleet’s enablers, following the Prime Minister’s announcement of 110 shadow fleet related sanctions earlier this month.

Targets include John Michael Ormerod, a British national who allegedly procured ships for Russia’s shadow fleet, and 2 Russian captains of shadow fleet tankers.

The UK is also working towards tightening the Oil Price Cap with a view to lowering the $60 crude price level closer to the cost of production to further restrict Russian revenues.

The full list of targets in this latest round of sanctions can be found here.

UK whistleblowing provisions

On 21 May 2025, the Department for Business Trade and Office of Trade Sanctions Implementation (“OTSI”) updated their guidance on reporting a suspected breach of sanctions by adding ‘Whistleblowing for trade sanctions’ section.

From 26 June 2025, UK law protecting whistleblowers will apply to employees and an employee will be able to make a whistleblowing disclosure to OTSI about a person or business they think is committing a breach of trade sanctions that are implemented and enforced by OTSI. The wrongdoing that is disclosed must be in the general public’s interest.

Further to this, on 26 June 2025 the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 will enter into force, which amends whistleblowing legislation to strengthen the enforcement of UK sanctions. Matters that can be disclosed to the Secretary of State for Business and Trade and Secretary of State for Transport will be expanded to include those concerned with sanctions. The Treasury will also be added as a person to whom whistleblowing disclosures can be made when to do with a matter concerned with sanctions.